Revenue Ruling 99-6 and Section 1031: Bob and Jon’s Excellent Adventure—Part II
Bob and Jon were the members of Apartment LLC, an LLC taxed as a partnership, with Bob owning a 40% membership interest and Jon owning a 60% membership interest. Apartment LLC owned a small apartment building as its only asset. Things were going well with the apartment building.
One day Bob Continue Reading …
Revenue Ruling 99-5 and Section 1031: Bob and Jon’s Excellent Adventure—Part I
Jon was the sole member of Apartment LLC, a disregarded entity for tax purposes. Apartment LLC owned a small apartment building as its only asset. Things were going well with that apartment building.
Bob had some extra cash from golf winnings and was looking for a real estate investment. He saw Continue Reading …
Tax Provisions in the American Rescue Plan Act of 2021
On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”), a $1.9 trillion economic stimulus package and comprehensive COVID relief bill that provides a wide range of assistance to businesses and individuals. As with the COVID-related Acts preceding it, ARPA facilitates much of Continue Reading …
Section 1061’s Application to Real Estate Carried Interests (or Not)
Persons interested in investing in real estate may not have the capital to purchase or develop real estate. Ordinarily those persons will seek out investors to provide the capital, while retaining a profits interest in the venture (a “promote” in the real estate world) in exchange for managing and facilitating Continue Reading …
You Can Leave California (With the Right Facts)
This post follows up on an earlier post from December 12, 2020, titled “The Long Arm of California’s Franchise Tax Board.” That post described a recent opinion by California’s Office of Tax Appeals (OTA), Appeal of L. Mazer and M. Mazer, in which the OTA ruled in favor of Continue Reading …